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Ethics Bribery

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

China Compliance, From Someone Who Knows

In today’s compliance environment, though we see a robust debate on what the new US administration might mean for anti-bribery compliance, the new ISO standard, and the recent DOJ “Evaluation of Corporate Compliance Programs”...more

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

From Bottom Bunk to Top Mind

I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team....more

This Week in FCPA-Episode 53, the I left my heart in San Francisco edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian President Temer comes under corruption fire? 2. The turmoil at FIFA continues as FIFA’s...more

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Code of Conduct Week: Part III – Design of Your Code of Conduct

by Thomas Fox on

Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

by Thomas Fox on

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

My China Compliance Diary

When my supervision (probation) ended in January 2017, the US District Court in DC released my passport, and I could once again travel internationally. And with that milestone, a note of thanks to all the international event...more

Judged by the Company You Keep

by NAVEX Global on

Earlier this month news broke that the venerable British automaker Rolls-Royce had settled an international prosecution alleging that the company’s third-party intermediaries bribed local officials in Asia. The company agreed...more

ISO 37001: Let’s Talk Specifics

by NAVEX Global on

Some, though certainly not all, of the dust has settled since ISO 37001 published last fall. As compliance professionals grapple with the new standard, we thought it would be interesting to use the power of social media to...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

FCPA Predictions for 2017 (Part III of III)

by Michael Volkov on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Gluten Free Compliance

This past November, I had the pleasure of sitting down with Sean Freidlin, Marketing Manager of Compliance & Ethics at SAI Global, www.saiglobal.com  at The Little Beet Restaurant in NYC, to discuss my history with...more

The SEC’s Continuing Refinement of Internal Controls Enforcement

by Michael Volkov on

My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more

Coordinating Third Party Due Diligence and Procurement

by Michael Volkov on

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

by Michael Volkov on

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

Gearing Compliance to the Tasks at Hand

I recently had the opportunity to travel to Chicago for my first SCCE Compliance and Ethics Institute (CEI), and attended a session “Keeping Compliance Simple,” which was led by Ricardo Pellafone, CEO, The Broadcat...more

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

by NAVEX Global on

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

Good-Bye to Arnold Palmer and Revolutionizing Compliance

by Thomas Fox on

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

by Michael Volkov on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Shareholders Will Get to Trial in Petrobras Corruption Scandal Action

by Thomas Fox on

Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more

The Ethics Advisor: It’s Getting Hot in Here

by Best Best & Krieger LLP on

Ah, summertime. Beaches, BBQs, visits with familia, ethics developments, balmy nights … Wait – ethics? Yes, it’s true. The world of ethics and conflicts of interest es muy caliente this summer, with a couple of...more

Even Though the Supremes Vacated Former Governor McDonnell’s Bribery Conviction, Don’t Even Think of Ditching Your Ethics...

by K&L Gates LLP on

The Supreme Court of the United States voted unanimously on June 27, 2016, to vacate former Virginia Governor Robert McDonnell’s conviction under the federal honest services and extortion statutes. In doing so, the eight...more

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